James S. Rhodes, Ph.D.

Trestle Energy LLC
5580 La Jolla Blvd. Suite 429 La Jolla, CA 92037

July 27 , 201 5

Air and Radiation Docket and Information Center Environmental Protection Agency
Mailcode: 2822T 1200 Pennsylvania Ave., NW Washington, DC 20460

Docket: EPA

– HQ

– OAR

– 2015

– 0111

Dear EPA:

I appreciate the opportunity to provide comments on the Notice of Proposed Rulemaking entitled “Renewable Fuel Standard Program: Standards for 2014, 2015, and 2016 and Biomass

- Based Diesel Volume for 2017,” dated J une 10, 2015 ( “ 2015 NPRM ” )

, which represents an important step in implementing the Renewable Fuel Standard (“RFS”). I recognize and appreciate EPA’s thoughtful efforts in developing this proposed rulemaking, particularly in terms of the substantial evolut ion in EPA’s approach since the proposed rulemaking from November, 2013.

My comments address a variety of issues discussed in the proposed rulemaking and reflected in the underlying policy objectives, and provides suggestions for advancing those objective s through EPA’s rulemaking authority. They build directly on the comments I provided to the 2013 NPRM entitled “ 2014 Sandards For The Renewable Fuel Standard Program,” dated November 29, 2013 (“2013 NPRM), which
is attached only for ease of reference . Th ese comments are based on my professional experience with transportation fuel policy, both in academia and in the private sector , which is summarized in my
comments to the 2013 NPRM . My academic work focuses broadly on engineering and economic analysis of technologies for mitigating anthropogenic GHG emissions and on policy analysis at the intersection of energy, environment, and climate change. My private sector work focuses on using existing policy incentives to support development of low emission energ y systems.

Of particular relevance in this context is my experience from my most recent academic position, in which I served for two years as the Managing Director for the National LCFS (“N

- LCFS”) Study, and from my current position as President of Trestl e Energy LLC. The N

- LCFS Study was a collaborative initiative led by a group at the University of California, Davis and included researchers from six research institutions. Trestle Energy is small energy company developing low carbon transportation fuels in response to established policy instruments. In the context of the RFS, Trestle Energy is developing systems to dramatically reduce lifecycle carbon emissions from biofuel production. Integrating these systems with bio

- refineries producing butanol or sorghum ethanol, for example, can enable rapid expansion of economically efficient advanced biofuel production. In so doing, these systems will seed development of whole new industries for domestically produced renewable energy that can drive downgreenho use gas emissions and improve environmental quality while creating demand for new green jobs

and new opportunities for economic development.

Trestle Energy’s systems provide an opportunity to make big gains toward the policy objectives underlying the RF S

— expanding domestic production of low carbon renewable fuels, driving down greenhouse gas emissions from domestic sources, improving energy security, creating jobs, and accelerating economic growth.

General comments on the 2015 NPRM

As a whole, t he 2015 NPRM reflects a balanced and well

- reasoned approach to address ing the diverse
issues that have recently challenged effective implementation of the RFS. EPA deserves substantial credit for the significant evolution in its analysis and rationale underpinning the volumes proposed in
this NPRM

. In particular, I commend EPA for:

1. Setting volumetric mandates at levels that aim to balance the fuel volumes achievable in the
market with the gro wth in supply envisioned in the statutory volumes established by congress;

2. Providing continued support for investments made in good faith to advance the policy objectives by providing steady increases

— and avoiding absolute decreases

— in RVO volumes ;

3. Cryst alizing pressure on the so

- called “ethanol blend

- wall” by establishing volumes that can be met by either (i) increasing ethanol beyond the blend

- wall or (ii) increasing supplies of non

ethanol renewable fuels;

4. Signaling a shift in supply growth

— consistent with the statutory volumes established by

congress

— toward advanced biofuels with increasing greenhouse gas emissions benefits ;

5. Recognizing the contributions to key policy objectives of competition among fuels within the implied pool for “ unspecified advanced biofuel s”, and advancing these objectives by growing this pool through an increasing gap between the sum total of the RVOs for D3 RINS, D4 RINS, D7 RINS, and the RVOs for Advanced Biofuels ;

6. Recognizing the diverse compliance pathways available to market participants and the implications of competitive dynamics for increasing renewable fuel supplies , as reflected in the analysis underlying Table II.D.2

- 2 in the 2015 NPRM, for example ;

Two a dditional sets of comments focus o n the following issues :

1. Establishing RVOs that reflect the maximum achievable volumes of renewable fuels (in response to requests for comments on pages 33122 and 33123); and

2. The relative growth in fuel volumes for Biomass

- Based Diesel, unspecified advanced biofuels

, and total renewable fuels (in response to requests for comments on pages 33122, 33123, 33137);Comment on establishing RVOs that reflect maximum achievable fuel volumes : EPA should consider

increasing the 2016 RVO for Advanced Biofuel by approximat ely 650 Million ethanol

- equivalent gallons and increasing the 2016 RVO for Renewable Fuels by approximately 340 Million ethanol

- equivalent gallons.

Through a number of statements, the 2015 NP RM makes clear EPA’s intention to use its waiver authority only to the extent required to bring the RVO’s within the market’s reach and to establish RVOs
that target maximum achievable renewable fuel volumes. I generally support this basic approach for

se tting the RVOs , which appears to be broadly consistent with the legislative intent and underlying policy objectives . I also appreciate that the timing of EPA’s issuance of 2014 and 2015 RVOs inherently limits their ability to influence fuel supplies delivered in the 2014 and 2015 compliance periods . That said, a nalyses contained within the 2015 NPRM and the 2013 NPRM seem to suggest that the proposed 2016 RVOs are significantly below the maximum achievable renewable fuel volumes.

For example, the 2015 NPRM projects the volume of ethanol that can be supplied as E10 is 13.69 Billion gallons [ 2015 NPRM pp. 331 15 ], and the 2013 NPRM projects that the maximum volume of biodiesel that can be consumed by the existing vehicle fleet is 2.7 Billion gallons [ 2013 NPRM pp. 71764

- 71765 of
the 2013 NPRM , and summarized on page 13 of the comments attached ]. The ethanol

- equivalent volume of this biodiesel is 4.05 Billion gallons, which approximates the maximum achievable volume for
the current vehicle fleet and is 650 Million ethanol

- equivalent gallons more than the RVO for Advanced
Bio fuel proposed in the 2015 NPRM for 2016

. A dding this ethanol

- equivalent volume to the volume of
ethanol that EPA projects can be supplied as E10 suggests a total achievable renewable fuel volume of 17.74 Billion ethanol equivalent gallons , which is 340 Mi llion gallons more than the RVO for Total
Renewable Fuel proposed in the 2015 NPRM for 2016

.

The simplified calculations above suggest that potentially significant increases in the RVOs for Advanced
Biofuel and Total Renewable Fuels may be possible with in EPA’s proposed framework to target
maximum achievable volumes of renewable fuels. The 650 Million ethanol

- equivalent gallons would represent a more than doubling of the 500 Million gallons of “unspecified advanced biofuels” implied by the 2016 RVOs prop osed in the 2015 NPRM [pp. 33136]

. Importantly, these simplified calculations should yield a conservative estimate of the maximum achievable volumes, because they ignore potential contributions from higher ethanol blends (e.g., E15 and E85) and from other non

- ethanol renewable fuels (e.g., renewable diesel, butanol, biomass based heating oils, renewable jet fuels, etc.).

On this basis, and specifically in response to requests for co mments on pages 33122 and 33123 of the
2015 NPRM

, I respectfully submit that EPA consider i ncreasing the 2016 RVO for Advanced Biofuel by approximately 650 Million ethanol

- equivalent gallons and increasing the 2016 RVO for Total Renewable
Fuels by approximately 340 Million ethanol

- equivalent gallons

.

Comment on the relative growth in fuel volumes for Biomass

- Based Diesel, Advanced Biofuels, and
Total Renewable Fuel : EPA should consider shifting annual increases in RVOs toward the fuel pool implied for unspecified Advanced Biofuels.

Integrating various concepts expressed in the 2015 NPRM highlights the importance of relative growth across renewable fuel types, particularly across Biomass

- Based Diesel (“BBD”), unspecified advanced biofuels, and conventional biofuels. In particular, the 2015 NPRM discusses the importance of continued growth in both the implied pool for conventional biofuels and in the Advanced Biofuel carve

-out for Biomass

- Based Diesel (“BBD”) in order to support the health and continued development of

these fuel industries , which have delivered the greatest contributions to the RFS policy objectives. EPA also notes the important contributions that result from the implied pool for unspecified advanced
biofuels

— i.e., from having an RVO for Advanced Biofuels that is greater than the sum of the carve

- outs for Cellulosic Biofuel s and BBD. EPA further notes both the benefits of increasing the implied pool for unspecified advanced biofuels over time and the increasing difficulty of supplying each increment of
additional renewable fuels.

Integrating these comments highlights the importance of balancing growth in fuel supplies across the se key fuel pools in order to effectively advance the underlying policy objectives . Th e proposed RVOs reflect one way that growth across these fuel pools may be balanced. Specifically, c onsidering the RVOs proposed for 2015 and 2016 suggests increases in the required volumes of BBD, unspecified advanced biofuels, and conventional renewable fuels of 100, 250, and 600 Million gallons, respectively. The growth in these pools is directionally correct and seems reasonable given the historical volumes in each of these pools, the congressional intent underlying the RFS, and the trend to systematically increase contributions from advanced biofuels.

That said, as discussed in the 2015 NPRM (and on pages 5

- 6 and 9

- 13 of the attached comments to the 2013 NPRM), the unspecified Advanced Biofuel pool has a particularly important role. It encompasses a broad range of fuel types that deliver systematic increases in both climate benefits and diversification of
feedstock or fuels. The diversity of fuel types within this pool supports a healthy level of c ompetition

, thereby providing st rong incentives for innovation to advance both economic and environmental performance. In particular, as the implied pool for conventional biofuels approaches its statutory limit, the growth in renewable fuels may be shifted to the unspecified advanced po ol to further incentivize innovation, diversification, and additional climate benefits from continued expansion of renewable fuels. Moreover, i nherent qualities of Advanced Biofuels (e.g., minimum carbon intensity reductions) provide a concrete means of achieving measurable progress toward the program’s underlying policy objectives despite recent delays in the scale up in Cellulosic Biofuel supplies

.

On this basis , and specificall y in r esponse to requests for comment on pages 33122, 33123, 33137 of the
2015 NPRM

, I respectfully submit that RVOs increasingly shift growth in required fuels supplies toward unspecified A dvan ced B iofuels

.James S. Rhodes

, Ph.D.

Trestle Energy LLC
5580 La Jolla Blvd. Suite 429 La Jolla, CA 92037

December 20, 2013

Air and Radiation Docket and Information Center Environmental Protection Agency
Mailcode: 2822T 1200 Pennsylvania Ave., NW Washington, DC 20460

Docket: EPA

– HQ

– OAR

– 2013

– 0479

Dear EPA :

I appreciate the opportunity to provide comments on the Notice of Proposed Rulemaking entitled “ 2014 Sandards For The Renewable Fuel Standard Progr am ,” dated November 29, 2013 ( “ NPRM ” )

, which represents an important step in implementing the Renewable Fuel Standard (“RFS ”). I recognize and appreciate EPA’s thoughtful efforts in developing this rulemaking, which a ims to leverage the policy
mechanisms available under the regulation to put the RFS on a “manageable trajectory” that balance s the fundamental policy objectives, the practical challenges to achieving those objectives, and the
broader challenges inherent to motivating industrial scale innovatio n in transportation fuel supplies

.

My comments address a variety of issues discussed in the proposed rulemaking and reflected in the underlying policy objectives, and provide s suggestions for advancing those objectives through EPA’s rulemaking authority. They are based on my professional experience with transportation fuel policy, both in academia and in the private sector. My academic work focuses broadly on engineering and economic analysis of technologies for mitigating anthropogenic GHG emissions and on policy analysis at the intersection of energy, environment, and climate change

. My private sector work focuses on using existing policy incentives to support development of low emission energy systems.

Of particular relevance in this context is my experience from my most recent academic position, in which I served for two years as the M anaging Director for the National LCFS (“N

- LCFS”) Study, and from my current position as President of Trestle Energy LLC . The N

- LCFS Study was a collaborative initia tive led by a group at the University of California, Davis and included researchers from six research
institutions. Trestle Energy is small energy company developing low carbon transportation fuels in response to established policy instruments. In the co ntext of the RFS, Trestle Energy is developing systems to dramatically reduce lifecycle carbon emissions from biofuel production

. Integrating these systems with bio

- refineries producing butanol or sorghum ethanol, for example, can enable rapid expansion o f economically efficient advanced biofuel production. In so doing, these systems will seed develop ment of whole new industries for domestically produced renewable energy that can drive down greenhouse gas emissions and improve environmental quality while creating demand for new green jobs and new opportunities for economic development

.Trestle Energy’s systems provide an opportunity to make big gains toward the policy objectives

underlying the RFS

— expanding domestic production of low carbon renewable fuels , driving down greenhouse gas emissions from domestic sources , improving energy security, creating job s, and accelerating economic growth . We very much look forward to working with the EPA to advance these objectives and the Administration ’ s broader policy goals for energy, the environment, and economic development.

My comments on the NPRM are organized as follows:

1. C omments on EPA’s approach to put ting the RFS2 on a “ manageable trajectory ” ( in response to requests for comments on page 71738 ) , with recommendations that:

a. Any shifts in EPA’s implementation should reflect the public

- private partnership implicit
to the RFS and continue support for private sector efforts to advance EPA’s policy goals ;

b. Any shifts in EPA’s implementation should mai ntain strong incentives for innovation to advance the underlying policy objectives, particularly in advanced biofuels ;

c. The “ manageable trajectory ” be supported in the rulemaking process for establishing new fuel pathways by:

i. Integrating industry

- analysis of proposed fuel pathways that are consistent with and appropriately leverage EPA’s considerable analytic efforts to date; and by

ii. Prioritizing fuel pathway petitions according to the potential scales of their
contributions to volumetric mandates, as well as the ir time to deployment.

2. C omments on supply constraints related to the so

- called E10 blendwall ( in response to requests for comments on pages 71734, 71754, and 71778 ) , with recommendation s to adopt a
framework that :

a. M aintains incentives to overcome the E10 blend wall ;

b. Supports continued innovation in fuel supplies required to advance the policy objectives; and

c. I s achievable even if the E10 blendwall proves to be a binding constraint.

3. Comments on EPA’s approach to setting the a dvanced biofuel volumetric mandates ( in response to requests for comments on pages 71738 ) , with recommendations that :

a. The volumetric mandates retain the policy’s strong emphasis on developing innovative fuel supplies required to advance the policy obje ctives;

b. The implied preference ordering for ethanol prioritize a dvanced biofuel ethanol at least as highly as “ conventional ” biofuel ethanol ; andc. The a dvanced biofuel mandate reflect quantities of advanced biofuels, including
biomass

- based d iesel that “could reasonably be achieved”, without regard to the RVO
for biomass

- based diesel or to potential changes to the biodiesel tax credit.

I f I were to condense these various comments into a single, actionable recommendation for the 2014
RVOs it would be this: define RVOs for a dvanced biofuel and total renewable f uels at levels reflect ing EPA’s expectation for advanced biofuel supply, including biodiesel supply

, without regard to potential
interactions with the biodiesel tax credit. The NPRM prov ides a number of reasons why the biomass

based d iesel RVO is set below the expected supply. T hese reasons may be appropriate in that context

, but they do not appear to be appropriate for defining the a dvanced biofuel or total renewable f uel
RVOs

. Moreove r, w hile potential changes in the tax code (e.g., elimination of the biodiesel tax credit) may affect the economics of renewable fuel production, and therefore the volume of biodiesel available absent the RFS, it will not affect the currently available cap acity to produce or supply the fuels to vehicles. Integrating this recommendation with the framework recommended in the NPRM & EPA’s projection for ethanol consumption in 2014 might yield, for example, the following target volumes :

Table 1. Summary example for 2014 RVOs
Cellulosic biofuel 8

– 30 million gallons a
Biomass

- based diesel 1.28 billion gallons b
Advanced biofuel 2.4

– 5. 2 billion gallons c
Total r enewable fuel 15.4

– 17.3 billion gallons a

a Ethanol

- equivalent gallons.

b Physical gallons, equal to 1.92 ethanol

- equivalent gallons.

c Ethanol

- equivalent gallons, equal to 1.6

– 2.7 billion physical gallons of biomass

- based diesel plus up to 1.1 billion gallons of
other advanced biofuels (30 milli on gallons cellulosic, 132 million gallons of non

- ethanol non

- cellulosic, and up to 942 million gallons
of non

- cellulosic advanced ethanol )

.Comments regarding EPA’ s approach to put the RFS on a “manageable trajectory”

(Per request on page 71738 )

The Notice of Proposed Rulemaking for the 2014 standards (NPRM) reflects EPA’s intentions and thoughtful efforts to define a framework that puts the RFS “ on a manageable trajectory while supporting growth in renewable fuels over time” and that advances the “central policy goals underlying the RFS program: reductions in greenhouse gas emissions, enhanced energy security, economic developmen t, and technological innovation” ( NPRM Pp 71732 and 71734

, respectively)

. It is important that such a framework be clear ly defined, both to enable effective future rulemaking and to support the continued private investments required to achieve the underlying policy objectives

. The NPRM generally reflects a thoughtful approach by EPA in this regard. The comments and sugges tions provided here are respectfully submitted with the intent of supporting EPA’s ongoing efforts refine its approach to implementing the RFS

.

A ny shifts in EPA’

s implementation should reflect the public

- private partnership implicit to the RFS and continue support for private sector efforts to advance EPA’s policy goals

. To be successful, implementation must take a balanced and coordinated approach that reflects the public and private

sectors ’ respective roles under the RFS

. Generally speaking , the role of the public sector (i.e., Congress and the EPA) is to clearly define the p olicy objectives and the policy incentives for advancing them (e.g., RVOs) . The private sector’s role is to harness market forces and mobilize private resources in order to respond effectively to the policy incentives and advance the policy objectives. While a balanced and coordinated approach is required for effectively implementing any such market

- based environmental policy, it is particularly important for the RFS because advancing its ambitious policy objectives requires
that large investments in technology development and infrastructure be sustained over extended period s of time in the face of large technical and economic uncertainties

.

In this context, poli cy uncertainty should be minimized as much as is practical in order to support effective private

- sector engagement. A ny shifts in policy implementation

— which may well be appropriate in light of evolving dynamics

— sh ould be designed to support continued pri vate

- sector engagement , particularly by parties that have already invested in the policy’s success. With this in mind,

p olicy shifts should , among other things, strive to:

 Limit stranded capital, particularly where associated investments were made in a g ood faith effort to advance the policy objectives ;

 Support opportunities to realign private sector resources in ways that progressively advance the underlying policy objectives ;

 Provide sufficient notice for such realignments to be implemented.

These principles are intended to buttress the integrity and credibility of the RFS and of other federal environmental policy instruments . Advancing environmental policy priorities of all types requires considerable investments by the private sector. Thes e investments are subject to large risks from a variety of sources, which must be internalized by the private sector. P olicy shifts

— even those viewed as appropriate course corrections

— risk devaluing, or even stranding, private sector investments made in

g ood faith to advance the policy . Such impacts will generally increase the perceived policy risk associated with environmental policy initiatives and may substantially compromise the private sector’sability to respond effectively to future policy initiati ves . This

, in turn

, risks undermining the

government’s ability to leverage market

- based policy mechanisms to advance key environmental policy objectives.

This dynamic creates an implicit public

- private partnership in advancing the RFS and other market

- based environmental policy instruments. Among other things, it creates particular responsibility for public sector agencies that any shifts in implementation be thoughtful ly designed and executed in a way that respects the implicit partnership with the pr ivate sector. The importance of this dynamic, and the principles suggested above, should not be overstated; however, they do seem relevant to potential shifts in EPA’s implementation of the RFS.

The NPRM’s aim to define a clear framework for prospective rulemaking is broadly consistent with these principles, particularly in signaling how issues related to the E10 blendwall will be addressed moving
forward. Potential compromises to private capital deployed to advance the policy could be fu rther limited by minimizing any absolute reductions in renewable fuel volume obligations (RVOs) from prior year (e.g., 2013 ) values . Structuring RVOs to support r ealignment of private sector resources by, for example, converting facilities producing “conv entional ” renewable f uels to a dvanced biofuel , c ould both protect capital investments while supporting continued progress toward the policy’s underlying objectives

. Further s uggestions for how these principles might be operationalized in the RVOs for 2014 and beyond are provided in the comments and recommendations below.

A ny shifts in EPA’

s implementation should maintain strong incentives for innovation to advance the underlying policy objectives , particularly in a dvanced biofuel s

. Innovation is critical to advancing the policy objectives underlying the RFS . The RFS was specifically amended in the Energy Independence and Security Act of 2007 to establish a market “ pull” for domestic ally produced renewable fuels that
advance the un derlying policy objectives. Accomplishing this requires substantial innovation in
renewable feedstock supplies

, fuel production, and distribution systems . Innovation on this scale requires sustained investments over an extended period of time in the face of inherently unpredictable

outcomes

. The RFS accommodates these characteristics by adopting clear, technology

- neutral performance metrics, by projecting a coherent set of targets for renewable fuel supply , and by enabling EPA to adjust that trajectory i n response to evolving market dynamics

.

While important innovations continue to develop in the production of so

- called “ conventional ” biofuels, the innovation required to achieve the policy’s underlying objectives must ultimately come from the

a dvanced b iofuel pool. It is a dvanced biofuel s that ensure increasing climate benefits and continued growth in renewable fuel supplies over time. As such, a dvanced biofuel s will, by design

, do much of the “heavy lifting” required to advance the policy’s underlying objectives moving forward

.

The m arket signal to develop advanced biofuels, transmitted through the Renewab le Identification Number (“RIN ”) market, responds rapidly to EPA’s rulemaking and to expectations regarding future rulemaking. An implementation framework yielding RVOs that emphasize contributions from advanced
biofuels (e.g., the 2013 RVOs) signals industry to supply more of these fuels, which is translated into premium RIN value s for advanced biofuels that enable investment into increasing produ ction capacity. Conversely, an implementation framework yielding RVOs that de

- emphasize advanced biofuels signals industry not to increase supplies of these fuels, which is translated into relatively low RIN value s for
advanced biofuels that cuts investme nts to increase production capacity

. In this way, RVOs that de

emphasize advanced biofuels effectively close opportunities to investment in develop ing advanced

biofuels and can undermine the value of prior investments made to advance the policy

.

On the one hand, the presence of this dynamic is generally a positive sign, indicating that RIN markets are responsive to RFS policy signals to increase the supply of fuels with improved environmental performance (e.g., advanced biofuels)

. At the same time, i t means that the role of advanced biofuels must be consistently emphasized within the implementation framework and associated RVOs in order to realize the environmental benefits and policy objectives associated with advanced biofuels

.

This is a dynamic tha t I witness first

- hand in my efforts to develop low emission energy systems

— capital investments flow into and away from advanced biofuel production according to the expected RVOs

. As a result, industry’s ability to invest in low emission advanced biofuels depends on the RVOs and broader implementation framework that EPA adopts. A dopting the RVOs and implementation framework proposed in the NPRM , which effectively de

- emphasize advanced biofuels, will substantially reduce my ability

— and the ability of indus try as a whole

— to commercialize production of low emission advanced biofuels.

In addition, the ability for diverse types of emerging renewable fuels to qualify as advanced biofuels ensures a competitive market for satisfying advanced biofuel RVOs, thereby enhancing the policy’s economic efficiency. The NPRM notes the flexibility resulting from the ability of biodiesel to compete with other advanced biofuels in satisfying the advanced biofuel RVOs ( Pp 717 53 ). It does not , however,
discuss the broad er implications of this flexibility for setting and satisfying advanced biofuel RVOs , which can be met with a variety of fuel type s. Some are currently available in large volumes (e.g., biodiesel and sugarcane ethanol), while others are more emergent (e.g ., reduced emission sorghum ethanol, reduced emission butanol, renewable diesel, renewable CNG, etc.)

. This diversity ensures a competitive market for supplying advanced biofuels.

In addition to enhancing the policy’s economic efficiency, this competit ive environment also provides a
clear market opportunity for innovation in supplying advanced biofuels. The marginal costs of supplying advanced biofuels that are currently available in large volumes (e.g., biodiesel and sugarcane ethanol)

set a clear ly d efined target for emerging advanced biofuels. Adopting RVOs that maintain pressure to supply these currently dominant fuel types ensures that RIN markets accurately reflect marginal costs of production, thereby providing a meaningful price signal to devel opers of emergent advanced biofuels. Reducing the RVOs from such levels collapses the premium value of advanced biofuels, which creat es slack in the market

, obscures the market

- clearing price, and effectively distort s the price signal for developer s of eme rgent fuel supplies

. In this way, RVOs that emphasize advanced biofuel s provide critical support for emerging renewable fuels, even if they are initially satisfied with currently dominant
sources of biodiesel and sugarcane ethanol.

For these reasons

, I respectfully suggest that EPA adopt RFS RVOs that maintain consistently strong
incentives for a dvanced biofuel production

. Such incentives are important for support ing sustained
investment s in innovative production systems that advance the underlying policy objectives

.

More broadly

, I suggest that the framework adopted by EPA to put the RFS on a “manageable trajectory” reflect a strong and increasing emphasis on innovation in supplying a dvanced biofuel s

. Specific sugges tions for how this might be operationalized with respect to the proposed 2014 RVOs are provided in the comments and recommendations below.The “manageable trajectory” adopted by EPA should be reflected in the rulemaking process es for

establishing new fue l pathways . The notion of establishing a “manageable trajectory” for the RFS is an important one, and one that should be reflected throughout EPA’s implementation of the policy . There

are many areas where this notion could be applied . The processes for establishing new fuel pathways
stand out as being particularly relevant and suitable for applying this principle in clear, actionable ways

.

Establishing new fuel pathways represents a critical aspect of the RFS. It enables fuels to contribute
toward th e volumetric mandates and is a key step in commercializing new renewable fuel production systems. It is a prerequisite for accessing RIN markets , which provide economic incentives for fuel production , and a s a result it can be a key factor in financing development of novel production systems

— from research through commercial deployment s . Uncertainty in the ability to qualify a fuel
under particular renewable fuel categories can substantially compromise development efforts. Therefore, a ccelera ting the process for establish ing new renewable fuel pathways

— particularly those capable of making substantial contributions to near

- term volumetric targets

— could substantially
accelerate commercial production of fuels that advance the underlying policy ob jectives. This could provide important contributions toward putting the RFS on a “ manageable trajectory. ”

Accelerating petition processing requires a strategic approach by EPA due to the resource intensity and
administrative demands associated with lifec ycle assessment and related analytic requirements. There is no substitute for diligent analysis and the potential benefits of accelerated processing do not justify compromises in technical rigor . That said

, at least two strategies may help accelerate EPA’s p etition processing and better align EPA’s efforts in this process with the stated intent of establish ing a

“ manageable trajectory ” for the program.

The first strategy is t o incorporate industry

- developed lifecycle assessments of proposed fuel production systems with in petition processing, so long as those assessments are consistent with and appropriately leverage EPA’s considerable analytic effort to date

. Industry has substantial capacity to conduct technically rigorous analysis, including lifecycle as sessments of potential renewable fuel pathways. EPA could leverage this capacity by enabling industry to develop lifecycle assessments of fuel production according to novel pathways using assessment methods and assumptions appropriate to EPA’s petition

pro cessing requirements. While EPA’s framework for assessing lifecycle impacts of feedstock supply

may not lend itself to industry analysis, lifecycle assessment of the biofuel production stage can arguably
be developed as credibly by industry as by EPA staf f. This approach has been adopted by California’s Air
Resources Board in implementing the lifecycle assessment requirements of the California Low Carbon
Fuel Standard. California’s experience to date suggests that the approach can be effective in leverag ing relatively limited agency resources to provide technically rigorous lifecycle assessments for many potential fuel pathways.

EPA could adopt a similar approach, in which industry is encouraged (or perhaps even required) to develop lifecycle assessment s of proposed fuel production systems as part of a petition to EPA. EPA staff c ould then critically evaluate the industry

- developed assessment to ensure it is consistent with EPA’s requ irements and analyse s to date

. Upon the satisfaction of EPA’s staff r egarding the methods, assumptions, and technical rigor of industry

- developed assessments, the results could be integrated with results of EPA’s internally developed lifecycle assessments of feedstock supply.

This approach could be facilitated by adopting a specific lifecycle modeling framework for assessing the fuel production process, such as the GREET model, which EPA adopted for determining emissions factorswithin its established lifecycle assessment framework. I ndustry

- developed assessments could the n be

required to clearly specify any modifications to the standard model that are required to effectively characterize the fuel production process of interest. This would substantially simplify EPA’s critical review of industry

- developed lifecycle assessments.

The benefit of this approach is that it would limit EPA’s analytic requirements of specific production systems to critically reviewing industry

- developed analyses. While this is a non

- trivial task, it is substantially less resource

- intensive than developi ng original assessments for each potential fuel pathway. As a result, this approach could substantially increase the processing capacity of EPA’s existing analytic staff and consequently accelerate petition process ing

.

The second strategy is for EPA to prioritize petitions for processing according to the scale of potential
contributions toward volumetric mandates ( in addition to the expected time to commercialization ) . EPA has a considerable backlog of petitions to evaluate and process. This is unders tandable, given the unlimited number of potential fuel pathways and the substantial resource s requirement to develop

assessments with the appropriate technical rigor, as discussed above. In this context it is sensible that EPA prioritize petition processi ng according to particular attributes of the proposed fuel pathways

. The regulation currently stipulates that petitions for fuel pathways that are “...closer to the commercial production stage than others” be prioritized (EPA. 2010. Final Rule . Pp 14681). This criterion is appropriate, but not sufficient for putting the program on a “manageable trajectory

, ” because it may prioritize fuel pathways that can be commercialized in the n ear term, but are not capable of producing
fuel s in the quantities required to achieve the policy’s proximate volumetric targets or to substantially
advance the underlying policy objectives. For this reason

, I respectfully suggest that EPA prioritize fuel

pa thway petitions according to both the expected time to commercialization and the scale of potential contributions to volumetric targets.

Comments on supply constraints recognized in the proposed rulemaking (Per request s on page s 71734 , 71754, and 71778 )

A substantial portion of the NPRM, and a key aspect of the proposed framework for putting the RFS on a “manageable trajectory

, ” relates to the E10 blendwall, which refers to the ethanol volume equivalent to blending all gasoline with 10% ethanol by volume

. The E10 blendwall has been an important consideration in the context of the RFS at least since the program amendments in EISA2007. While the E10 blendwall may be reached earlier than originally envisioned, EPA’s current expectations (as
indicated in th e NPRM) appear to be consistent with those indicated in the Regulatory Impact Analysis dated February 2010 , which projected the E10 blendwall to be reached in the 2013 to 2015 timeframe ( EPA 2010 . Figure 1.7

- 3 ).

Overcoming the E10 blendwall is an important milestone toward achieving the policy objectives underlying the RFS . Scaling up renewable fuel supplies to the levels originally envisioned is only possible
if the E10 blendwall is ove rcome, and leveraging such renewable fuel productio n to advance climate and other important policy objectives similarly requires overcoming the E10 blendwall. Reducing volumetric mandates to levels below the E10 blendwall, and codifying this approach in th e implementation framework moving forward would therefor substantially compromise the ability to continue advancing the underlying policy objectives. Such an approach would effectively remove all policy incentives for developing the strategies required to o vercome the E10 blendwall. It would risk creating a self

- fulfillingprophecy, locking the country into a future falling far short of the regulatory intent , and truncating our

ability to effectively advance the underlying objectives.

For these reasons, I respectfully submit that the framework adopted by EPA to implement the RFS moving forward should embody the following attributes:

1. It should m aintain strong incentives for overcoming the E10 blendwall , as this is a prerequisite to advancing the underlying policy objectives;

2. It should be achievable even if the blendwall represents a binding near

- term constraint on ethanol consumption; and

3. It should maintain strong ince ntives for developing innovative systems for producing renewable
fuels that adv ance the u nderlying objectives.

RVO s for a dvanced biofuel represents a potentially important policy tool for accomplishing this in a way that is consistent with the comments provided above

. A variety of factors support this view, including:

 Advanced biofuel volum es can be met with advanced ethanol or a variety of non

- ethanol advanced biofuels that are unaffected by t he E10 blendwall (e.g., biodiesel , butanol, and compressed natural gas produced from renewable feedstock);

 Many types of a dvanced biofuel produce more than one “ethanol

- equivalent” gallon for every physical gallon supplied (e.g., one gallon of biodiesel yields 1.5 ethanol

- equivalent gallons)

, which provides additional leverage fro m available production capacity;

 There is substantial und er

- utilized production capacity for advanced biofuel (the NPRM projects
2013 biodiesel production below 1.8 billion gallons despite a total capacity of 3.6 billion gallons ), which supports substantially increasing volumetric targets;

 There is substantial potential to convert biorefineries from producing conventional biofuels to

a dvanced biofuel (e.g., ethanol plants to butanol production and corn ethanol plants to sorghum ethanol), which provides opportunities to realign private capital investments ; and

 There are a wide variety of pathways for producing advanced biofuels, providing an inherently competitive market for ongoing innovation to advance the underlying policy objectives.

Taken together, these factors suggest that RVOs for advanced biofuels can provide incentives to advance the underlying policy objectives and overcome the E10 blendwall, while providing enough flexibility to enable compliance even if the E10 blendwall represents a binding constraint. For example, the advanced biofuel RVO might b e set near the upper end of the range that might be “reasonably achievable” using non

- ethanol advanced biofuels, recognizing that these fuels would compete with
advanced ethanol ( i.e., ethanol qualifying as and advanced biofuel), to the extent increasing ethanol
volumes can be delivered as E15 or E85. The availability of substantial excess biodiesel production capacity , the potential for ethanol plant retrofits (e.g., to butanol)

, and the potential for other advanced
biofuels supports a robust, diverse, and competitive market for meeting ambitious volumetric targets

.Comments on EPA’s approach to setting the a dvanced biofuel volumetric mandates

(Per request s on page 71738 )

Th e a dvanced biofuel category is particularly important for advancing the underlying policy objectives. As noted above, i t is designed to do much of the “heavy lifting” in that regard by providing continued growth, diversity, innovation, and climate benefits in renewable fuel supplies

. Industry’s ability to invest in advancing these policy objectives depends directly on the RVOs and on market expectations for the RVOs, as noted above.

In this context

, I respectfully submit that RVOs should retain the policy’s strong and increasing emphasis

on developing a dvanced biofuel s

.

The NPRM highlights the merits of a strong and growing role for advanced biofuels (Pp 7177 4 ), which I broadly support. I have two general observations regarding the framework p roposed in the NPRM for defining a dvanced biofuel RVOs that are relevant in this context

. The first is that the proposed
framework for defining RVOs appears to codify a long

- term preference for “conventional” ethanol above advanced ethanol, which seems to be inconsistent with the policy’s objectives and legislative intent.
The second is that the analysis used to define biomass

- based diesel supplies toward achieving the
advanced biofuel RVO is not representative of the volume that “could reasonably be achieved” (NPRM Pp 71752 ), for reasons specified in the NPRM (NPRM Pp 71752

- 71753 and 71762

- 71766 ), and therefore does not app ear to provide a reasonable basis for defining advanced biofuel RVOs consistent with the intent noted above, the legislative intent, or underlying policy objectives

. These comments are discussed further below, after which an example is provided for how 2014 RVOs might be defined in a
manner that seems on its face to be mo re consistent with both the principles discussed above and with
the intent underlying the general approach recommended in the NPRM.

The proposed framework for defining RVOs appears to codify a long

- term preference for “conventional”
ethanol over advanced ethanol

. Unde r the RFS, e thanol can be supplied within three different renewable fuel categories, depending on how it is produced : cellulosic b iofuel (i.e., ethanol from
cellulosic feedstock ) ; non

- cellulosic a dvanced biofuel (e.g., ethanol from grain sor ghum or sugarcane ) ; and “conventional” renewable fuel (including ethanol from a variety of feedstock types)

. As a result, the
RVOs (and differences between the RVOs) for these fuel categories reflect an implicit allocation of ethanol production volumes ac ross them . The impl ications of this allocation are substantially magnified
under the approach recommended in the NPRM, which aims to accommodate challenges from the E10
blendwall by systematically reducing the RVOs from the legislated targets

.

Relevant a spects of the proposed approach are detailed on pages 71754 and 71775 of the NPRM, but are effectively summarized on page 71738 as follows:

“For total renewable fuel, we would project the volume of ethanol that could reasonably be consumed as E10 and higher ethanol blends, and would add to that the
volume of all non

- ethanol renewable fuels that could reasonably be expected to be
available. Fo r advanced biofuel , we would sum the ethanol

- equivalent volumes of the cellulosic biofuel requirement [including cellulosic ethanol], the biomass

- based diesel requirement, and the additional non

- ethanol advanced biofuel that could reasonably be expected to be available and consumed.” [NPRM Pp28]As this excerpt indicates, the total renewable fuel RVO would account for all of the ethanol that is

capable of being supplied within the constraints of the E10 blendwall, while the advanced biofuel RVO accounts only for et hanol provided as cellulosic biofuel. While excluding non

- cellulosic advanced
ethanol s from the determination of the advanced biofuel RVO does not prevent them from contributing
toward the mandate, it implies that there will be little room for them to contribute toward the RVOs
once the separately mandated cellulosic and biomass

- based diesel portions are satisfied. As a result,

e xcluding non

- cellulosic advanced ethanol from the determination of the advanced biofuel RVO implicitly allocates all ethan ol supplied within the E10 blendwall into either the cellulosic biofuel category or the non

- advanced “conventional” category. This implies preferences for ethanol as follows:

Cellulosic ≻ Conventional ≻ Advanced

A potential benefit of adopting this approach is to maximize the volume of conventional renewable fuels
that can contribute to the total renewable fuel RVOs in the near term . This may be important for

preserv ing the value of capi tal already deployed to advance the R FS and for supporting continued
investments to advance the underlying policy objectives, as discussed above.

However, embedding this approach into the longer

- term implementation framework adopted to put the RFS on a “manageable trajectory” risks codifying t hese preferences over the long term. This would effectively remove incentives for developing advanced biofuel ethanol and for continuing progress toward the underlying policy objectives (e.g., reductions in greenhouse gas emissions). As such,

c odifying such preferences would be inconsistent with the policy’s objectives and legislative intent , as articulated in the NPRM (NPRM Pp 71774 )

.

With this in mind, I respectfully suggest that the framework adopted to put the RFS on a “manageable trajector y” reflect a progressive transition toward preferences for ethanol as follows:

Cellulosic ≻ Advanced ≽ Conventional

Or

Cellulosic ≻ Advanced ≻ Conventional

A rapid transition to such preferences m ay not be appropriate , given the intent to reduce total RVOs in response to challenges associated with the E10 blendwall , as t his could substantially compromise private capital investments made in good faith to advance RFS policy objectives. However

, it would be
reasonable to embed a progressive transition toward these preference s in the framework adopted to put the RFS on a “manageable trajectory

. ” A transition toward advanced biofuels, even under a binding E10 blendwall, c ould support the growing set o f options available for converting installed capital from producing “conventional” biofuels to advanced biofuel (e.g., butanol or sorghum ethanol with reduced
carbon emissions ) and advance associated policy benefits

. Codifying a transition toward the sugge sted ethanol preferences could therefore signal the private sector to begin realigning installed capital
without undermining prior investments made in good faith to advance the policy

.Implementing the recommended ethanol preferences could be accomplished by setting the advanced

biofuel RVO at a level that reflects a fraction of the potentially available volume of advanced biofuel
ethanol. The proposed 2014 RVOs include 0% of the potentially available supply in the advanced
biofuels R VO (implying a strict preference for “conventional” ethanol). In contrast, i ncluding 100% of potentially available advanced ethanol supply with in the advanced biofuel RVO would imply a strict preference for advanced ethanol. A progressive transition in e thanol preferences could be achieved by incrementally increasing the fraction of potentially available advanced ethanol that is included in each year’s advanced biofuels RVO

.

Th is approach would be more consistent with the general approach proposed in the NPRM . It reflects the availability of advanced biofuels and the constraints associated with the E10 blendwall, stated objectives of the proposed approach (NPRM Pp 71775 ), and it reflects broader policy objectives and legislative intent to progressively i ncrease supplies of advanced biofuels (NPRM Pp 71774 ). It is also broadly consistent with the balance of comments provided above.

The RVO for biomass

- based d iesel is not representative of the volume that can reasonably be achieved and therefore does not provide an appropriate basis for defining the advanced biofuel RVO

. The NPRM
describes considerable analysis by EPA regarding the factors relevant to defining the RVO for biomass

based diesel (e.g., NPRM Pp 71751

- 71754 ). In particular, t his section disc usses a variety of factors supporting the proposal to set biomass

- based diesel RVOs for 2014 and 2015 below the volume s that could reasonably be achieved , including:

 The statutory minimum volume of 1 billion gallons;

 The statutory timing requirements for promulgating new volume requirements;

 The flexibility inherent to utilizing biodiesel production in excess of the biomass

- based diesel
RVO in order to meet the advanced biofuel RVO; and

 The u ncertainty in expected biodiesel production volumes due to potential chang es in the tax code (i.e., potential termination of the biodiesel tax credit ).

These factors appear to be reasonable in the context of the biomass

- based diesel RVO

, with the possible except ion of potential changes to the biodiesel tax credit

. Prospective changes in the tax code could impact the economics of biodiesel supply, and therefore the volumes that might reasonably be available
absent the RFS; however, they do not, on their face, appear capable of changing “. . . the volumes of all

sourc es of advanced biofuel that could reasonably be achieved. . .”, which is the stated intent for defining advanced biofuel RVOs (NPRM Pp 71754 ). They cannot reduce biodiesel production capacity that is currently available, and they cannot change the volume that can be consumed by the current vehicle fleet. Moreover, the RFS is specifically designed to provide economic incentives for increasing renewable fuel production, irrespective of other policy instruments. In this context, it seems difficult to justif y interpreting the definition of “reasonably achievable” volumes to be contingent upon unrelated changes in the tax code.

On t his basis

, I respectfully submit ( i n response to the request for comments on page 71763 of the

NPRM ) that c hanges in the biodiese l tax credit should not be considered in EPA’s projection of biodiesel
volumes that could be available in 2014 or beyond.

Excluding potential changes in the biodiesel tax credit from EPA’s consideration does not necessarily
affect the conclusion s presente d in the NPRM for biomass

- based diesel RVOs, but would impactconclusions for advanced biofuel RVOs. The other factors noted above may continue to support setting

RVOs for biomass

- based diesel in 2014 and 2015 below the volume that could reasonably be achieved,
but n either the statutory minimum volume for biomass

- based diesel

, nor the statutory timing requirements noted above, appear relevant to RVOs for advanced biofuels or total renewable fuels.

The inherent f lexibility from biodiesel ’s ability to contribute toward advanced biofuels and total
renewable fuel RVOs , above and beyond the biomass

- based diesel RVOs, supports higher estimates of reasonably achievable volumes for these categories than is proposed for biomass

- based diesel

. Note that EPA’ s analysis of the potential “biodiesel blendwall” indicates that at least 2.7 billion physical gallons of biodiesel (2.8 billion gallons, less 3% due to cold weather constraints, equivalent to 4.1 billion
ethanol

- equivalent gallons) could be consumed by th e existing vehicle fleet (NPRM Pp 71764

- 71765 ).
This is substantially greater than projected production volumes, yet it remains substantially below the current biodiesel production capacity of 3.6 billion physical gallons (NPRM Pp 71763 ). Moreover, the variety of fuel types eligible to qualify as advanced biofuels

— including advanced biofuel ethanol, butanol, renewable compressed natural gas, etc.

— suggests that adopting advanced biofuel RVOs that are higher than proposed in the NPRM would support a compet itive environment for advanced biofuels

. This provides meaningful incentives to continue innovation toward advancing the underlying policy objectives.

On this basis, I respectfully submit ( in response to the request for comment s on page s 71734

, 71738

,
an d 71763 of the NPRM) that the RVOs for total renewable fuel s and advanced biofuels reflect the
volumes of biomass

- based diesel that can reasonably be achieved, without regard to either t he biomass

based diesel RVO or to the fate of the biodiesel tax credit

.

Example of 2014 RVO calculations consistent with the general approach proposed in the NPRM and with the recommendations provided in these comments.

The comments in this section provide an example of one way that the recommendations provided in
these c omments might be integrated with the general approach proposed in the NPRM to determine
2014 RVOs. It is intended to illustrate how the various principles discussed above might be translated
into RVOs

, but it is not a recommendation for specific RVO value s

.

Implementing the recommendation s above regarding the advanced biofuel RVO might imply adopting a range for achievable biomass

- based diesel s upply in the range of 1.6 to 2.7 billion physical gallons . 1.6 billion gallons reflects the minimum projected supply in 2013 . There is no reason to think that at least
this much biodiesel cannot be delivered in 2014 as well. 2.7 billion gallons reflects the maximum volume that might be supplied in light of EPA’s assessment of the biodiesel blendwall (NPRM Pp 717 64

- 71765 ). This may be viewed as the binding constraint on supply, given total production capacity of 3.6 billion gallons and falling feedstock prices (NPRM Pp 71764 ) . This range in physical volumes of biodiesel is equivalent to between 2.4 and 4.1 billio n ethanol

- equivalent gallons.

Adding this estimate of available biomass

- based diesel to EPA’s estimated range for domestic non

ethanol advanced biofuel available in 2014 of 24

- 132 million gallons (NPRM Pp 71776 ) , implies a potential range for non

- ethano l advanced biofuel s of 2.4 to 4.2 billion ethanol

- equivalent gallons.

Adding to this estimate a volume equivalent to some portion (between 0% and 100%) of the 328 to 942 million gallons of non

- cellulosic advanced ethanol biofuels potentially available in 2014

— in order tosignal a transition in ethanol preferences, as noted above

— implies a potential range for the 2014

advanced biofue l RVO of 2.4 to 5. 2 billion ethanol

- equivalent gallons

. (2.4 billion gallons allocates zero

non

- cellulosic ethanol to the advanced biofuel pool. 5. 2 billion gallons allocates 100% of the maximum
volume EPA determined to be potentially available non

- cellu losic advanced ethanol to advanced biofuels.)

According to the approach propos ed in the NPRM, the RVO for total renewable f uels would be defined by adding the estimated volumes of cellulosic biofuels, biomass

- based diesel

, and other non

- ethanol
advanced biofuels to EPA’s estimate for total ethanol consumption for 2014, which is in the range of 12.95 to 13.09 billion gallons (NPRM Pp 71762 ) . This approach implies a n RVO for total renewable fuels in the range of 15. 4 to 17.2 billion ethanol

- equivalent gall ons , ignoring any potential adjustments to EPA’s estimate of total ethanol consumption that may be appropriate

. These results are summarized in
the table below.

Table 2

. Example 2014 RVO range s consistent with the general approach proposed in the NPRM and with the recommendations provided in these comments. Proposed requirement for cellulosic biofuels 8

– 30 million gallons Proposed requirement for b iomass

- based diesel 1.28 million gallons (1.9 2 ethanol

- equivalent gallons)
Available volume of excess biomass

- based diesel 0.32

– 1.44 billion gallons ( 0 .4 8

– 2.15 billion
ethanol

- equivalent gallons)
Available volume of domestic non

- ethanol advanced biofuel 24

– 132 million ethanol

- equivalent gallo ns

Available volume of advanced ethanol (domestic ethanol and sugarcane ethanol imports) 328

– 942 million gallons

Total available volume of advanced biofuels 2. 7

– 5. 2 billion ethanol

- equivalent gallons Proposed requirement for advanced biofuels 2.4

– 5. 2 billion ethanol

- equivalent gallons
Total renewable fuels 15.4

– 1 7.3 billion ethanol

- equivalent gallons

Note that the example ranges for advanced biofuels and total renewable fuels in Table 2 are systematically higher than those recommended in the NPRM Table I

- 2. This results from adopting ranges for biomass

- based diesel supply that reflect reasonably achievable volumes, based on information provided in the NPRM, but excluding consideration of potential changes in the tax code and
other issues that are specific to the biomass

- based diesel RVO (rather than the advanced biofuel RVO). It also reflects allocating some portion (0% to 100%) of potentially available advanced ethanol to advanced biofuels in defining the advanced biofuel RVO.

The ranges p resented in this example support RVOs that could provide the following benefits :

1. Support capital investments made to advance the policy’s success by minimizing absolute reductions from 2013 RVO levels;

2. Provide incentives for increasing development of advanced biofuels , which would:

a. Provide incentives for continued innovation to advance the underlying policy objectives, even absent absolute increases in renewable fuel production;b. Maintain pressure on the E10 blendwall, through potential supplies of advanced ethanol, while enabling compliance if the blendwall is not overcome;

c. Signal the private sector to begin realign ing installed capital , where appropriate, toward advanced biofuel production;

The ranges in this example do not reflect recommendatio ns regarding fuel pathway petitions to accelerate EPA’s processing and to better align EPA’s efforts with its intent to provide a manageable trajectory for the policy. This might increase the volumes EPA estimates for potentially available
advanced biofue ls.

Thank you again for the opportunity to share comments as part of EPA’s rulemaking process. I look
forward to continuing to work with the agency on low

- emissions energy systems that support the nation’s 21 st century energy and environmental goals.

With kind est regards,

James S. Rhodes